PAIA

Private Body Manual

Manual prepared in accordance with section 51 of the Promotion of Access to Information Act No. 2 of 2000 for Synergy Evolution.

South AfricaPrivate body manualPublic access page

1. Contact details of the private body

1.1 Name of body: Synergy Evolution Private Limited ("Synergy Evolution")

1.2 Physical address: Clearwater Office Park, Corner Millenium Road & Christian de Wet Road, Clearwater, Johannesburg 1735

1.3 Postal address: 115 Wilde Amandel Avenue, Roodekrans, Roodepoort, 1724

1.4 Telephone: +27 (0) 64 524 8833, +27 (0) 10 007 5980, +27 (0) 76 350 5955

1.5 Head of body: Sihle John Nhlapo

1.6 Designated Accounts Advisory Services Manager: Mpho Nhlapo

1.7 Who we are: Synergy Evolution conducts business as an asset management specialist and complimentary business services and solutions provider across various sectors.

2. Section 10 guide

2.1In terms of section 10 of the Promotion of Access to Information Act No. 2 of 2000, the South African Human Rights Commission has published a guide containing information relating to:

2.1.1obtaining access to a record of a private body and the assistance that is available from the South African Human Rights Commission in this regard;

2.1.2lodging a court application against a decision by the head of a private body;

2.1.3the fees that are payable for accessing a record; and

2.1.4the voluntary disclosure of information by private bodies.

2.2The contact details of the South African Human Rights Commission are as follows:

Office: South African Human Rights Commission: PAIA Unit

Physical address: Braampark Forum 3, 33 Hoofd Street, Braamfontein, Johannesburg, Gauteng 2017

Telephone: 011 877 3600

Facsimile: 011 404 0668

Website: www.sahrc.org.za

Email: paia@sahrc.org.za

3. Section 52(2) notice

3.1No notice has been published.

4. Records available in terms of other legislation

4No notice has been published. Insofar as may be applicable, the group keeps records of information to the extent required in terms of, inter alia, the following legislation:

4.1Basic Conditions of Employment Act 75 of 1997;

4.2Broad Based Black Economic Empowerment Act No. 53 of 2003;

4.3Companies Act 71 of 2008;

4.4Compensation for Occupational Injuries and Diseases Act 130 of 1993;

4.5Consumer Protection Act 68 of 2008;

4.6Copyright Act 98 of 1978;

4.7Criminal Procedure Act 51 of 1977;

4.8Electronic Communications and Transactions Act 25 of 2002;

4.9Employment Equity Act 55 of 1998;

4.10Financial Intelligence Center Act 38 of 2001;

4.11Income Tax Act 58 of 1962;

4.12Insolvency Act 24 of 1936;

4.13Insurance Act 27 of 1943;

4.14Labour Relations Act 66 of 1995;

4.15Medical Schemes Act 131 of 1998;

4.16Occupational Health and Safety Act 85 of 1993;

4.17Protection of Personal Information Act 4 of 2013;

4.18Regulation of Interception of Communications and Provision of Communications-related Information Act 70 of 2002;

4.19Skills Development Act 97 of 1998;

4.20Skills Development Levies Act 9 of 1999;

4.21Unemployment Insurance Act 63 of 2001;

4.22Value-Added-Tax Act 89 of 1991.

5. Company records

5.1No notice has been submitted to the Minister of Justice and Constitutional Development regarding the categories of records which are available without a person having to request access in terms of section 52(2) of PAIA. The information on the website of the business, however, is automatically available without having to request access in terms of PAIA.

5.2General information about Synergy Evolution can be accessed via the internet at www.synergyevolution.co.za, which is available to all persons with access to the internet.

5.3Company records classification key.

Company records classification key
Classification number	Access	Classification
1	May be disclosed	Public access document
2	May not be disclosed	Request for, or after commencement of, criminal or civil proceedings [s7]
3	May be disclosed	Subject to copyright
4	Limited disclosure	Personal information that belongs to the requester of that information [s61]
5	May not be disclosed	Unreasonable disclosure of personal information of natural person [s63(1)]
6	May not be disclosed	Likely to harm the commercial or financial interests of a third party [s64(a)(b)]
7	May not be disclosed	Likely to harm a third party in contract or other negotiations [s64(c)]
8	May not be disclosed	Would breach a duty of confidence owed to a third party in terms of an agreement [s65]
9	May not be disclosed	Likely to compromise the safety of individuals or protection of property [s66]
10	May not be disclosed	Legally privileged document [s67]
11	May not be refused	Environmental testing or investigation that reveals public safety or environmental risks [s64(3)]
12	May not be disclosed	Commercial information of private body [s68]
13	May not be disclosed	Likely to prejudice research and development information of Synergy Evolution or a third party [s69]
14	May not be refused	Disclosure in the public interest [s70]

5.4Summary records availability.

Summary records availability
Departmental records	Subject	Classification
Communications and Corporate Affairs Division	Current product information	3
Communications and Corporate Affairs Division	Public corporate records	1
Communications and Corporate Affairs Division	Media releases	1
Environmental Division	Environmental policy	1
Environmental Division	Environmental records	11, 14
Human Resources Division	Employee records	4, 5, 8, 9
Human Resources Division	Employment contracts	4, 5, 8
Human Resources Division	Personnel guidelines, policies and procedures	13
Human Resources Division	Employee medical records	4, 5, 8, 9
Financial Division	Financial statements	1
Financial Division	Financial and tax records (company and employees)	1, 8
Financial Division	Asset register	1
Legal / Company Secretarial Division	General contract documentation	6, 10, 13
Legal / Company Secretarial Division	Company guidelines, policies and procedures	10, 13
Legal / Company Secretarial Division	Trade marks	3
Legal / Company Secretarial Division	Statutory records	1
Marketing and Sales Division	Market information	13
Marketing and Sales Division	Product brochures	1
Marketing and Sales Division	Marketing and product strategies	13
Marketing and Sales Division	Product sales records	13
Marketing and Sales Division	Customer information and customer database	5, 6, 9
Quality	Quality records	13

6. Purpose of processing of personal information

6.1provide our goods or supply our services;

6.2better understand our data subjects' needs when doing so;

6.3keep our data subject records up-to-date;

6.4manage employees in general;

6.5manage supplier contracts in general;

6.6manage dealer relationships in general;

6.7manage customers in general;

6.8manage customer credit in general;

6.9market to customers in various countries;

6.10enforce debts;

6.11market goods and services to prospects;

6.12engage with investors and the media;

6.13process customer requests or complaints; and

6.14process personal information of employees for forensic purposes.

7. Data subjects categories and their personal information

7.1contact details, such as phone numbers, physical and postal addresses, and email addresses;

7.2personal details, such as names and ages;

7.3demographic details, such as races and age groups;

7.4health information;

7.5biometric information;

7.6account numbers;

7.7background information;

7.8contract information;

7.9credit information;

7.10market intelligence information; and

7.11debt and debtor information.

8. Planned recipients of personal information

We give the following people personal information that we process in the ordinary course of business to fulfill our obligations to our customers or clients:

8.1Statutory authorities;

8.2Law enforcement;

8.3Tax authorities;

8.4Financial institutions;

8.5Medical schemes;

8.6Employee pension and provident funds;

8.7Industry bodies;

8.8contractors, vendors, or suppliers;

8.9agents, distributors, or other resellers;

8.10operators, other responsible parties, or co-responsible parties; and

8.11third-party vendors, such as software developers, to help us maintain our services.

9. Planned trans-border flow of personal information

9.1We may send personal information outside South Africa to various countries. We will only transfer data to other countries who have similar privacy laws to South Africa's or to recipients who can guarantee the protection of personal information to the same standard we must protect it.

9.2For more information on this, please see our privacy policy.

10. Security

10.1We secure our data by maintaining reasonable measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We also take reasonable steps to keep personal information accurate, current, complete and reliable for its intended use.

11. The request procedure

11.1Forms and fees

11.1.1A request for information must be made in the prescribed form, must be addressed to the Information Officer and must be submitted with the prescribed fee.

11.1.2The prescribed request form and details regarding the prescribed fees are available from the South African Human Rights Commission, whose contact details are set out in this document. The prescribed request form and prescribed fee details are available on the website of the Department of Justice and Constitutional Development at www.doj.gov.za.

11.2Form of request

11.2.1The requester must use the prescribed form to make the request for access to a record. This request must be made to the address, facsimile number or electronic mail address of the Information Officer and must contain the requester's postal address and facsimile number within the Republic.

11.2.2The requester must provide sufficient detail on the request form to enable the Information Officer to identify the record requested and the requester. The requester should also indicate which form of access is required. The requester should indicate if notice of the decision of the Information Officer is required in any manner, other than in writing, and if so, the necessary particulars to be so informed.

11.2.3In the request form, the requester must identify the right that is sought to be exercised or to be protected and provide an explanation of why the requested record is required for the exercise or protection of that right.

11.2.4If a request is made on behalf of another person, the requester must submit proof of the capacity in which the requester is making the request to the satisfaction of the Information Officer.

11.3Fees

11.3.1A requester who seeks access to a record containing personal information about that requester is not required to pay the request fee. Every other requester, who is not a personal requester, must pay the required request fee.

11.3.2The Information Officer must by notice require the requester to pay the prescribed fee, if any, set out in the notice, before further processing the request.

11.3.3The requester may lodge an application with a court against the payment of the prescribed request fee.

11.3.4After the Information Officer has made a decision on the request, the requester must be notified in the required form.

11.3.5If the request is granted then a further access fee must be paid for the search, reproduction, preparation, and for any time, in excess of the prescribed hours, required to search and prepare for the record disclosure.

12. Remedies

If request for access is denied, the requester may:

apply to a court with appropriate jurisdiction, or
lodge a complaint with the Information Regulator, for the necessary relief.

13. Availability of the manual

13.1This manual is available for inspection by the general public upon request during office hours and free of charge at Synergy Evolution's physical address as well as on Synergy Evolution's website, www.synergyevolution.co.za.

14. Updates to this manual

14.1This manual will be updated whenever we make material changes to the current information.